AML / Financial Crime

Key dates

2016-01-01

The period began during which the FCA found that the investor-visa scheme operated; the exact start date is not specified in the publication.

2019-01-01

The period ended during which the FCA found that the scheme operated; the exact end date is not specified in the publication.

2021-03-12

The FCA imposed restrictions preventing Dolfin from carrying on regulated activities, following concerns including its operation of the investor-visa funding scheme.

2021-06-01

Dolfin entered special administration; the exact date in June is not specified in the publication.

2022-02-17

The Home Office closed the Tier 1 investor visa route of entry to the UK.

2026-08-26

The FCA published the enforcement announcement concerning the bans, fines and Joukovski Decision Notice.

Suggested considerations

• Compliance teams may wish to review whether any product or client arrangement could create a misleading impression that a regulatory, immigration or other statutory investment threshold has been met when the client’s own qualifying capital is materially lower.
• Firms should consider testing the end-to-end governance of immigration-linked investment business, including approval of the business model, ownership and control disclosures, conflicts management, introducer due diligence, fee flows and oversight of connected or offshore entities.
• Firms may wish to reassess source-of-funds and source-of-wealth controls where client investments are supported by loans, circular funding, guarantees or funds provided by affiliated entities, and document why the resulting structure is consistent with the relevant immigration and financial-services requirements.
• Senior managers and boards should consider whether regulatory submissions, notifications and attestations fully disclose shadow directorships, controllers, beneficial ownership, related-party involvement and the true commercial purpose of client arrangements.
• Firms should consider conducting targeted reviews of historical investor-visa or residence-by-investment clients, including communications and files supplied to regulators or other public authorities, and escalating any potentially misleading statement or omission through the appropriate remediation and notification processes.
• Training and surveillance may be reviewed to ensure staff understand that conduct outside the core regulated service, including assistance with immigration-rule circumvention, can affect the firm’s and individuals’ integrity, fitness and propriety.
• Where third-party immigration agents or introducers are used, firms may wish to assess their incentives, remuneration, representations to clients, due-diligence records and ongoing monitoring, particularly where fees are unusually high or linked to visa approval.

What changed

This is a final enforcement outcome for Nagy and Maraj, not a new generally applicable rule or supervisory requirement. Both were prohibited from performing any function in relation to regulated activities; Nagy’s discounted penalty was £324,800, compared with an undiscounted £464,000, and Maraj’s discounted penalty was £122,000, compared with an undiscounted £174,300. Joukovski was issued a Decision Notice proposing a prohibition order, but the proposed action has no effect pending the Upper Tribunal’s determination.

Key dates

2026-08-21

Request for Comment published in the Federal Register.

2026-10-20 Deadline

Comments are due, calculated as 60 days after Federal Register publication.

2026-10-05

Reported target date for CME Group and Silicon Data to list two compute or GPU-rental futures contracts, subject to regulatory review; this date is not established by the CFTC Request for Comment.

Suggested considerations

• Compliance teams may wish to determine whether the firm has relevant empirical data on compute prices, volumes, counterparties, supplier concentration, utilization, capacity commitments, or bilateral contract terms that could support a CFTC submission.
• Potential DCM and SEF applicants should consider mapping proposed contract specifications and settlement methodologies against CEA section 5(d), Core Principles 2, 3, 4, 5, 9, and 11, 17 CFR 38.150-38.160, 38.200-38.201, 38.250-38.258, 38.500, and 38.603, and the guidance in 17 CFR part 38 appendices B and C.
• Firms developing or contributing data to a compute index should consider documenting data provenance, publication practices, governance, auditability, contributor concentration, observation-window controls, fallback mechanisms, and safeguards against manipulation by capacity providers.
• FCMs, introducing brokers, and other intermediaries may wish to assess whether existing BSA/AML, KYC, onboarding, suitability, disclosure, and market-conduct controls address the risks identified for compute derivatives, including opaque bilateral markets and geopolitically sensitive supply.
• Market participants may wish to submit comments by the applicable deadline, clearly referencing RIN 3038-AF77 and the Request for Comment on the Listing of Compute Derivatives Contracts, while avoiding unnecessary personal or confidential business information because submissions will be publicly posted.
• Firms tracking product development should consider monitoring any subsequent DCM self-certification or Commission-approval filing, as the consultation itself does not authorize trading or postpone a proposed listing.

What changed

No final rule, approval, prohibition, or new compliance obligation was introduced. The CFTC is requesting comment on compute cash-market size, liquidity, transparency, supplier concentration, fungibility, benchmark methodology, deliverable supply, manipulation risks, surveillance feasibility, customer protection, heightened BSA/AML and KYC issues, retail protections, and the design and risks of perpetual compute futures.

Key dates

2026-05-22

Switzerland added 115 natural persons and organisations to its Russia-related sanctions list; approximately 2,790 persons, companies, and organisations are now subject to asset freezes in connection with Russia’s war against Ukraine.

2026-08-19

The Federal Council decided to adopt the further measures of the EU’s 20th Russia sanctions package according to Switzerland’s established practice.

2026-08-20 Deadline

The new measures entered into force, including the prohibition on using Russian platforms for crypto-asset transfers and exchanges and the prohibition on supporting development of specified Russian crypto-assets such as the digital rouble.

Suggested considerations

• Firms should consider updating sanctions screening rules, prohibited-platform lists, wallet and counterparty controls, and transaction-monitoring scenarios to identify Russian crypto-asset platforms and indirect use of those platforms.
• Crypto-asset firms should consider mapping all transfer, exchange, custody, brokerage, technical-support, wallet-access, and infrastructure services against the applicable provisions of the Ordinance on Measures connected with the Situation in Ukraine, including the newly prohibited Russian platforms and specified Russian crypto-assets.
• Compliance teams may wish to review exposure to the digital rouble and other Russian or rouble-linked crypto-assets, including holdings, listings, liquidity provision, development support, transfers, and third-party integrations, and document any required exit or blocking decisions.
• Firms should consider validating that assets of sanctioned natural persons, companies, and organisations are blocked and that affected business relationships are reported to SECO in accordance with the sanctions ordinance.
• Firms should consider establishing or refreshing procedures for prompt escalation of sanctions-related suspicions, including additional clarifications under Article 6 GwG and an immediate Article 9 GwG report to the Money Laundering Reporting Office where suspicions cannot be dispelled.
• Senior compliance and operations owners may wish to evidence implementation from 2026-08-20 through control attestations, blocked-transaction testing, vendor and platform due diligence, and documented review of open Russian-related relationships.

What changed

The Switzerland-Russia sanctions regime now prohibits the use of Russian platforms for crypto-asset transfers and exchanges, targeting alternative payment channels that could facilitate sanctions circumvention. It also prohibits support for the development of specified Russian crypto-assets, including the digital rouble; independent market commentary places this measure alongside restrictions concerning Russian crypto-asset service providers, sanctioned trading venues, wallet or account access, technical assistance, and certain rouble-backed assets such as RUBx and A7A5, although the FINMA...

Key dates

2021-01-01

The FCA’s permanent restriction on marketing speculative illiquid securities, including relevant mini-bonds and loan notes, to retail investors took effect under COBS 4.14.

2026-01-01

The UK regime regulating offers of securities to the public came into force under the Public Offers and Admissions to Trading Regulations 2024.

2026-07-16

Robert Goodhew and Andrew Stoneman of Kroll Advisory were appointed joint administrators of Woodville Consultants Ltd.

2026-08-20

The FCA publication was updated and warned consumers and market participants about risky mini-bonds, loan notes and related financial promotions.

Suggested considerations

• Compliance teams should inventory current and proposed promotions, introducer arrangements and distribution channels involving loan notes, mini-bonds, litigation funding, private credit or other potentially speculative illiquid securities.
• Firms should document the classification analysis under FCA COBS 4.14, including whether the security is speculative and illiquid, whether it is excluded from the restriction, and the precise exemption relied upon for any retail communication.
• Authorised firms should verify that every financial promotion is made or approved within the firm’s permission and competence, is fair, clear and not misleading under FCA Principle 7 and COBS 4, and contains sufficiently prominent explanations of capital-loss, liquidity, issuer-default and compensation-scheme risks.
• Firms should not rely solely on an investor’s self-certification as a high-net-worth or sophisticated investor; compliance teams may wish to test the basis, timing, wording and evidence for each investor-status declaration against the applicable Financial Promotion Order exemptions.
• Banks, payment firms and professional intermediaries should consider enhanced onboarding and transaction-monitoring controls for unusual high-yield investment flows, unexplained introducer commissions, overseas exchange references, trust structures and claims of FCA-regulated involvement that may create a misleading halo effect.
• Distribution agreements should clearly identify fees, commissions, conflicts and the party responsible for the promotion, with controls to prevent unauthorised introducers from soliciting UK retail investors or passing them to unauthorised issuers.
• Firms should assess whether a proposed public offer engages the Public Offers and Admissions to Trading Regulations 2024 and related FCA requirements, while treating that assessment as separate from financial-promotion, authorisation, conduct and investor-protection analysis.
• Relevant firms and professional intermediaries should retain evidence of due diligence, approvals, investor categorisation, risk disclosures, payment flows and complaints handling, and consider reporting suspicious activity or unlawful promotions to the FCA.

What changed

The FCA has reiterated that speculative illiquid securities, including most mini-bonds and loan notes, have been subject to a permanent restriction on their marketing to retail investors since 1 January 2021 under FCA COBS 4.14. The restriction does not make every loan note unlawful or bring every issuer within FCA authorisation; firms must separately assess whether the instrument falls within the restricted category, whether an exemption applies, and whether the promotion is made or approved by an authorised person in accordance with the Financial Services and Markets Act 2000 and the...

Key dates

2020-01-01

The FCA's temporary product intervention restricting mass-marketing of speculative illiquid securities to retail investors took effect.

2020-12-10

The FCA published PS20/15, confirming permanent rules for marketing speculative illiquid securities, including speculative mini-bonds, to retail investors.

2021-01-01

The permanent FCA restrictions on mass-marketing speculative illiquid securities to ordinary retail investors came into force.

2026-08-19

The FCA published the consumer warning following continuing losses and concerns about unregulated loan notes and mini-bonds, including the collapse of Woodville Consultants Limited.

2026-08-20

The FCA page was updated; the publication continues to operate as a warning and supervisory or enforcement signal rather than a new rule.

Suggested considerations

• Compliance teams may wish to inventory all loan notes, mini-bonds, debentures, preference shares, and comparable securities promoted, approved, advised on, arranged, or distributed by the firm.
• Firms should consider testing each product against the FCA definition of a speculative illiquid security, including the denomination threshold of less than £100,000, the use of proceeds, transferability, listing, and the applicable exemptions.
• Authorised firms should consider blocking mass-market communications, including websites, social-media advertising, broad email campaigns, affiliate content, and introducer activity, where the promotion is likely to reach ordinary retail clients.
• Where an exemption is relied on, firms should consider evidencing investor eligibility, the basis for any high-net-worth or sophisticated-investor status, the timing and validity of the investor declaration, and controls preventing onward dissemination to ineligible persons.
• Firms approving or communicating relevant promotions should consider verifying that required risk warnings, loss-of-capital disclosures, liquidity and default information, and third-party fee or commission disclosures are accurate, prominent, and consistent across all distribution channels.
• Due diligence should consider whether claims such as asset-backed, secured, FCA-authorised security trustee, listed, or fixed return accurately describe the legal and economic position of investors.
• Compliance teams may wish to review introducer agreements, commission arrangements, marketing costs, investor-money flows, and the proportion of subscriptions actually applied to the underlying investment.
• Firms should consider checking that communications do not use artificial deadlines, pressure tactics, unrealistic return comparisons, or performance claims unsupported by a credible explanation of repayment capacity.

What changed

No new binding requirement or prohibition was introduced by this publication. The FCA restated that its permanent rules prohibit authorised firms from approving or communicating financial promotions for speculative illiquid securities in a manner likely to be received by retail clients, subject to defined exemptions.

Key dates

2026-08-18

The competent UN Sanctions Committee amended the ISIL (Da’esh) and Al-Qaida sanctions list; the amendment became directly applicable in Switzerland.

2026-08-19

SECO updated the SESAM database and published the Swiss sanctions-list adjustment.

2026-08-20

FINMA published the updated sanctions notice describing the amendment and related financial-intermediary obligations.

Suggested considerations

• Compliance teams may wish to obtain the 2026-08-19 SESAM update and identify precisely which persons, companies or organisations were added, amended or removed.
• Firms should consider refreshing sanctions-screening data and screening customers, beneficial owners, counterparties, payment parties, securities positions and existing business relationships against the amended entries without delay.
• Where a potential match is identified, firms should consider applying the relevant prohibitions, preventing disposal or transfer of assets, documenting the match analysis and escalating the case under their sanctions procedures.
• Firms should consider reporting affected business relationships and frozen assets to SECO in accordance with SR 946.231.08 and retaining evidence of the report and asset-freeze decision.
• A SECO sanctions report should not be treated as a substitute for AML controls; where indicators give rise to suspicion, compliance teams may wish to conduct the additional clarifications required by Article 6 GwG and file an immediate MROS report under Article 9 GwG if the suspicion cannot be dispelled.
• Firms with delegated or outsourced screening may wish to verify that vendors refreshed their Swiss sanctions data after 2026-08-19 and that payment and transaction-monitoring controls cover the amended list.

What changed

The sanctions list under the Swiss Ordinance of 2025-03-21 on measures against persons and organisations associated with ISIL (Da’esh) and Al-Qaida (SR 946.231.08) was amended following the UN committee decision of 2026-08-18. The publication does not identify the amended entries or specify whether they are new designations, amendments or delistings; firms should therefore reconcile the current SESAM data against their prior screening population. The amendment applies in Switzerland directly and without a separate Swiss legislative adoption step.

Key dates

2026-08-14

The competent UN sanctions committee amended the ISIL (Da’esh) and Al-Qaida sanctions list; the amendment became directly applicable in Switzerland under the applicable automatic-implementation framework.

2026-08-17

SECO updated the Swiss-authoritative SESAM sanctions database and published the corresponding list adjustment.

2026-08-19

FINMA published its notice reporting the SECO sanctions-list update.

Suggested considerations

• Compliance teams may wish to retrieve the 17 August 2026 SESAM update and reconcile it against the prior list, recording all additions, removals and amendments and preserving the source version used.
• Firms should consider rerunning customer, beneficial-owner, counterparty, payment, trade and custody screening against the amended list, including historical transactions and open orders where their risk-based controls require retrospective review.
• Firms should consider reviewing transliterations, aliases, dates of birth, nationality, incorporation data and other identifiers for any newly listed individual or entity to reduce false negatives and false positives.
• Where a potential match is identified, firms should consider applying the prohibitions and asset-freeze requirements under SR 946.231.08, escalating the case under their sanctions procedures and assessing whether notification to SECO is required.
• Compliance teams may wish to verify that vendor feeds, transaction-screening systems, watchlists, case-management workflows and manual escalation procedures reflect the direct-applicability model and the 17 August SESAM update date.
• Firms should consider documenting the timing of list ingestion, screening completion, disposition of alerts, any blocked or frozen assets, and any reports or licence requests submitted to SECO for audit and supervisory purposes.

What changed

The UN sanctions committee changed the list of sanctioned individuals, companies and organisations covered by SR 946.231.08. Switzerland applies the change directly, without a separate Swiss legislative or regulatory adoption step. SECO updated SESAM, the SECO Sanctions Management database described as authoritative for Switzerland, on 17 August 2026 and published the amendment on its website.

Key dates

2025-09-10

Tricolor and affiliates filed for Chapter 7 bankruptcy and moved toward liquidation.

2025-12-17

The U.S. Attorney’s Office for the Southern District of New York announced criminal charges against Tricolor executives in connection with the alleged fraud.

2026-08-18

The SEC announced the civil enforcement action against Daniel Chu, Jerome Kollar, and Ameryn Seibold in the U.S. District Court for the Southern District of New York.

Suggested considerations

• Firms should consider performing a targeted review of whether the same receivable, loan, vehicle, inventory item, or other asset can be pledged across multiple warehouse facilities, securitizations, lenders, or managed accounts, including through affiliates and special-purpose vehicles.
• Compliance teams may wish to test collateral eligibility and borrowing-base reporting back to source-level records, payment histories, lien and ownership data, servicing systems, and independent third-party evidence rather than relying solely on management certifications.
• Securitization sponsors, underwriters, and investors should consider reviewing controls for detecting loans that are delinquent, charged off, non-paying, fictitious, materially impaired, or otherwise ineligible but reported as current or eligible.
• Firms should consider reconciling loan-level collateral tapes across all funding channels and establishing exception escalation, independent sign-off, segregation of duties, and documented remediation for duplicate identifiers or inconsistent pledging data.
• Finance and compliance functions may wish to assess whether offering documents, investor presentations, lender certificates, and management meetings accurately describe liquidity constraints, funding needs, collateral encumbrances, and portfolio performance.
• Boards and senior-management committees should consider reviewing governance over collateral operations, securitization disclosures, liquidity reporting, related-party or affiliate financing, and controls over executive certifications.
• Investment managers and lenders may wish to incorporate independent collateral verification, borrowing-base audit rights, data-access rights, concentration and duplication analytics, and covenant triggers into new and renewed transactions.
• Firms with relevant exposure should consider preserving records, communications, collateral tapes, system audit trails, certifications, underwriting files, and exception reports in light of parallel SEC and criminal proceedings.

What changed

The publication does not introduce a new rule, threshold, filing requirement, or compliance deadline. It announces an enforcement complaint under the antifraud provisions of the Securities Act of 1933 and Securities Exchange Act of 1934, including alleged control-person liability against Chu and aiding-and-abetting liability against all three defendants. The SEC seeks injunctions, disgorgement with prejudgment interest, civil penalties, and officer-and-director bars against Chu and Kollar.

Key dates

2026-08-17

EAER amended Annexes 12, 13 and 14 and SECO updated the SESAM sanctions database.

2026-08-18 Deadline

The amendment became legally effective at 23:00 Swiss time; affected prohibitions, asset freezes and SECO reporting obligations applied from that time.

Suggested considerations

• Compliance teams may wish to obtain the effective 2026-08-18 23:00 SESAM dataset and run an immediate rescreening of customers, beneficial owners, authorised signatories, counterparties, payment beneficiaries, securities positions and relevant transaction history.
• Firms should consider applying the Article 16 asset-freeze and availability prohibitions to positive matches, including assets or economic resources controlled indirectly, and escalating potential matches for ownership-and-control analysis rather than relying only on exact-name screening.
• Financial intermediaries should consider reporting affected business relationships and frozen assets to SECO without delay in accordance with the ordinance, while documenting the screening timestamp, match disposition, freeze decision and notification trail.
• Teams may wish to review pending and recurring Iran-related payments against Article 21, including the CHF 10,000 SECO reporting threshold, the five-working-day reporting period, and the CHF 50,000 prior-authorisation threshold.
• A SECO sanctions report should not be treated as a substitute for AMLA analysis: where circumstances create suspicion, firms should consider additional clarifications under Article 6 AMLA/GwG and an immediate MROS report under Article 9 AMLA/GwG if the suspicion cannot be dispelled.
• Firms should consider reviewing delisted and amended entries separately, because removal from an Iran annex does not necessarily resolve exposure under other Swiss, UN or foreign sanctions regimes or eliminate unrelated AML, proliferation-financing or reputational-risk concerns.
• Compliance and operations teams may wish to confirm that screening vendors, payment filters, case-management workflows, correspondent-bank controls and sanctions procedures recognise the 23:00 Swiss-time effective moment and preserve an auditable change-management record.

What changed

The amendment updates the Swiss SESAM sanctions database and the designation annexes of the Ordinance of 12 December 2025 on measures against the Islamic Republic of Iran. Six individuals were delisted, one entity record was amended, and two individuals and one entity were newly listed; the publication does not identify the parties in the FINMA notice itself, so firms should rely on the current SECO SESAM data rather than the notice's entry counts alone.

Key dates

2026-08-14

EAER amended Annexes 2 and 14a of the Ukraine Ordinance; one entity was removed from Annex 14a and 610 Annex 2 individual and entity entries were amended.

2026-08-17 Deadline

The amendments and resulting prohibitions, asset-freezing requirements and reporting implications take effect at 23:00 Swiss time; firms should have implemented screening and control changes by this time.

Suggested considerations

• Compliance teams should load the amended Annex 2 and Annex 14a data into sanctions-screening systems and complete identifier, alias, ownership and account-linkage checks before the 17 August 2026 23:00 effective time.
• Firms should compare the pre-amendment and post-amendment lists to distinguish the Annex 14a deletion from the 610 amended Annex 2 entries and should avoid treating an amended record as cleared without validating the current consolidated list.
• Firms should review customers, beneficial owners, counterparties, payment instructions, securities positions, custody assets and correspondent relationships against the amended records, including possible indirect ownership or control links.
• Where a match is confirmed, firms should consider stopping prohibited activity, freezing relevant funds and economic resources, restricting access in accordance with the Ordinance, and reporting the affected business relationship to SECO using the applicable reporting channel and form.
• For suspected sanctions evasion, inconsistent customer information or other money-laundering indicators, compliance teams may wish to document the Article 6 AMLA enhanced clarification and assess whether an immediate Article 9 AMLA report to the Money Laundering Reporting Office is required.
• Firms should document screening-rule changes, alert disposition, freeze decisions, SECO notifications, AMLA escalation decisions and any controlled release following the Annex 14a removal. Any unblocking should be preceded by checks for separate Annex 2 designation, ownership or other sanctions grounds.

What changed

The EAER amended Annex 2 and Annex 14a of SR 946.231.176.72. The official government notice indicates that one entity was removed from Annex 14a and the entries concerning 610 individuals and entities were amended in Annex 2; the publication does not state that all 610 entries are new designations, so firms should obtain and compare the underlying consolidated and delta lists before determining the precise status of each relationship. Financial intermediaries must implement the applicable prohibitions, freeze assets of sanctioned persons, and report affected business relationships to SECO.

Key dates

2026-08-13

The competent UN Sanctions Committee amended the ISIL (Da’esh) and Al-Qaida list; independent notices describe amendments to four entries.

2026-08-14

SECO updated the Swiss SESAM database and published the corresponding Swiss sanctions-list update.

2026-08-17

FINMA published its updated sanctions notice drawing attention to the directly applicable Swiss list change.

Suggested considerations

• Compliance teams may wish to obtain the amended UN list and the updated SESAM data, identify the three amended individuals and one amended entity, and map all aliases, dates of birth, nationalities, addresses, registration details and other identifiers into screening systems.
• Firms should consider immediate rescreening of customers, beneficial owners, authorised signatories, counterparties, vendors, payment beneficiaries and relevant historical transactions against the amended data.
• Where a potential match is identified, firms should consider suspending the relevant transaction or relationship pending a documented false-positive assessment and escalating a confirmed or unresolved match to sanctions, legal and MLRO governance channels.
• For a confirmed match, firms should consider applying the asset-freeze restrictions under SR 946.231.08, preventing funds or economic resources from being made available directly or indirectly to or for the benefit of the designated person or entity, and assessing applicable Swiss notification and reporting requirements.
• Firms should retain evidence of the SESAM and screening-data update, screening timestamps, alert dispositions, approvals, transaction holds and any regulatory or law-enforcement communications.
• Control owners may wish to test whether outsourced screening providers, payment filters, correspondent-bank interfaces and crypto blockchain analytics received the update without delay.
• Compliance teams may wish to note the market reading reflected in parallel official-industry notices: the practical expectation is operational list maintenance and prompt rescreening, not merely awareness of the FINMA publication.

What changed

The list entries covered by the Ordinance of 2025-03-21 on Measures Against Persons and Organisations Connected with ISIL (Da’esh) and Al-Qaida (SR 946.231.08) were amended; the available public notices indicate amendments to three individuals and one entity, rather than a new standalone FINMA rule. The amendments became directly applicable in Switzerland through the UN sanctions-list mechanism, and SECO incorporated them into SESAM on 2026-08-14.

Suggested considerations

• Firms should consider reviewing digital advertising, affiliate, referral and social-media monitoring for deepfake endorsements, unauthorised use of executive or brand identities, fake licence claims and links to cloned investment platforms.
• Compliance teams may wish to test whether the firm’s website address, legal entity name, AFSL number and contact details are consistently displayed and match ASIC’s Professional Registers Search, including any authorised representative relationships.
• Firms should consider implementing or refreshing rapid escalation and takedown processes for impersonation, cloned websites, fraudulent advertisements and misleading investment promotions, with documented evidence of referrals to platforms, banks, ASIC, cyber.gov.au and Scamwatch where appropriate.
• Marketing and distribution controls may wish to require provenance and approval checks for celebrity, influencer, public-figure and AI-generated content, together with surveillance for fabricated reviews, news articles and testimonials.
• Risk and governance functions should consider assessing AI-enabled scam and impersonation scenarios within financial-crime, cyber-risk, operational-resilience and consumer-harm frameworks, including scripted follow-up calls, fake trading dashboards and small initial profit payments used to build trust.
• Firms should consider reviewing customer and counterparty onboarding controls for entities claiming to hold an AFSL, and escalation procedures where an opportunity encourages consumers to bypass licensed professionals or cannot be independently verified.
• Boards or risk committees may wish to receive trend reporting on impersonation incidents, customer complaints, fraudulent domains, takedown requests, losses and control remediation, notwithstanding that this media release itself imposes no new reporting requirement.

What changed

No new rule, mandatory control, reporting obligation or compliance deadline was introduced. ASIC has reinforced its expectation that consumers independently verify Australian Financial Services Licence details against the professional registers, including matching the licence holder’s name and number to the business or opportunity being promoted. The warning also indicates that reliance on search-engine results, polished websites, branding, testimonials, celebrity endorsements or claims of ASIC licensing is insufficient where firms or consumers assess legitimacy.

Key dates

2026-08-14

Effective date of FinCEN final rule "Beneficial Ownership Information Reporting Requirement Revision" (91 FR 52508; RIN 1506-AB67), permanently narrowing CTA BOI reporting to foreign reporting companies and codifying exemptions for U.S. persons and domestic reporting companies.

Suggested considerations

• Compliance teams at foreign reporting companies should review the revised 31 CFR 1010.380 definition of "reporting company" and confirm that their entity meets the narrowed criteria (foreign formation plus registration to do business in a U.S. State or Tribal jurisdiction), updating BOI reporting inventories and scoping accordingly.
• Foreign reporting companies should update BOI reporting procedures to ensure that reports capture beneficial owners who are non-U.S. persons while excluding U.S. person beneficial owners, including revising data collection forms, internal instructions, and system logic to avoid collecting or transmitting U.S. person BOI under the CTA framework.
• Firms involved in foreign pooled investment vehicles registered in the United States may wish to revise governance and reporting processes so that BOI reports for such vehicles identify only the individual exercising substantial control (or greatest authority over strategic management) who is not a U.S. person, and cease including U.S. controllers where they qualify as U.S. persons.
• Corporate secretarial and entity management functions should update CTA/BOI scoping matrices to remove domestic corporations, LLCs, and similar entities from BOI reporting obligations and to reflect that only qualifying foreign entities remain in scope, while maintaining awareness of other AML and KYC obligations that may still apply independently of the CTA.
• Onboarding and registration workflows for foreign entities should be reviewed so that BOI reporting triggers, timelines, and responsibilities are aligned with the final rule’s foreign-only scope, including any remaining deadlines tied to registration dates, and that staff understand that U.S. person company applicant information is no longer required for CTA reporting.
• Firms maintaining records of U.S. person beneficial owners and company applicants for CTA purposes may wish to reassess retention policies, ensuring that any continued collection or storage of such data is for other legal or risk-management purposes rather than CTA compliance, and that privacy notices and data minimization practices reflect the updated regulatory position.
• Compliance teams should revise CTA-related policies, procedures, and training materials to incorporate the exemptions for U.S. persons holding FinCEN IDs, clarifying that these individuals are no longer required to update or correct BOI previously provided to obtain the identifier, and documenting any residual obligations under other BSA or AML rules.
• Banks, broker-dealers, and other AML-regulated firms should consider the impact of reduced BOI availability for U.S. persons on their own customer due diligence, beneficial ownership, and risk assessment frameworks, and evaluate whether internal KYC standards or other regulatory requirements (such as customer due diligence rules) necessitate separate collection of U.S. person ownership information irrespective of FinCEN’s CTA exemptions.

What changed

The definition and scope of "reporting company" under 31 CFR 1010.380, as implemented under 31 U.S.C. 5336, are now permanently narrowed so that entities previously defined as domestic reporting companies are exempt from BOI reporting requirements, including initial, updated, and corrected BOI reports. Foreign reporting companies remain subject to BOI reporting, but the rule confirms that they are exempt from reporting beneficial ownership information for any U.S. person beneficial owners; those U.S.

Key dates

2019-11-01

Approximate start of the alleged fraudulent conduct described by the SEC

2023-06-30

Approximate end of the alleged fraudulent conduct described by the SEC

2026-08-13

SEC announced the enforcement action

Suggested considerations

• Compliance teams may wish to review whether any compensated solicitors or referral sources are engaging in broker-like activity without registration.
• Firms should consider testing whether solicitation, negotiation, and fund-collection roles could create broker-registration exposure under Exchange Act Section 15.
• Firms may wish to reassess use-of-proceeds controls and verify that investor funds are not being diverted outside disclosed purposes.
• Firms should consider enhancing monitoring for Ponzi-like payout patterns, especially where distributions appear funded by new investor money rather than operating cash flow.
• Compliance functions may wish to review marketing and fundraising materials for consistency with the firm’s actual registration status and authority.
• Firms operating in relationship-driven communities may wish to evaluate affinity-based fraud risk and strengthen independent verification of investors, counterparties, and cash flows.

What changed

This is an enforcement action, not a rulemaking or guidance release. The SEC complaint alleges that Leor Moshe solicited investments through Capital Funding ASAP LLC by claiming investor money would fund short-term business loans, while allegedly diverting more than $11 million for personal use and more than $850,000 for Ponzi-like payments to earlier investors.

Key dates

2026-06-15

The Financial Services Tribunal summarily dismissed the reconsideration application

2026-05-21

FSCA press release issued announcing the enforcement action

Suggested considerations

• Compliance teams may wish to map referral, lead-generation, and affiliate arrangements to assess whether the practical activity could be viewed as intermediary services rather than a pure introduction.
• Firms may wish to review digital marketing content, especially where potential returns or investment opportunities are promoted online.
• Businesses could consider whether staff or contractors who collect FICA documents, onboard clients, or answer product questions are performing regulated functions that require authorisation.
• Firms may wish to test whether commission structures tied to successful transactions increase the risk that an arrangement is characterised as regulated distribution rather than marketing support.
• Groups using third parties for introductions may wish to clarify contractual roles and operational boundaries, because the regulatory analysis may turn on conduct in practice rather than the label used in the contract.
• Where cross-border or offshore products are involved, firms may wish to review whether local authorisation, disclosures, and client-facing controls are sufficient for the nature of the offering.

What changed

The publication does not introduce new rules or amend the FAIS framework. It reports an enforcement outcome in which the FSCA concluded that Equitos Group and Linder were acting as referral agents for offshore UK property developers, promoting unlisted offshore property-linked investments, earning commission on successful referrals, and going beyond introductions by collecting and processing FICA documentation, facilitating client onboarding, and managing investor queries.

Key dates

2026-06-04

FSCA press release announcing administrative sanctions totalling R5.39 million

Suggested considerations

• Compliance teams may wish to review whether their risk management and compliance programme is current, documented, and aligned to FIC Act obligations.
• Firms may wish to test customer due diligence, beneficial ownership verification, and ongoing monitoring controls for consistency across onboarding and review processes.
• Compliance teams may wish to confirm that record-retention arrangements preserve required records for the statutory minimum period after a business relationship ends.
• Firms may wish to verify that FIC registration status and related governance records remain accurate and current.
• Boards and senior management may wish to assess whether escalation, remediation tracking, and internal testing are sufficient to evidence AML/CFT oversight under regulatory scrutiny.

What changed

This is an enforcement publication, not a rule change or consultation. The FSCA imposed administrative sanctions on Fairsure Administration (Pty) Ltd, Gray Swan Financial Services (Pty) Ltd, GQM Fund Administrators (Pty) Ltd, and Louw Risk Financial Services CC for non-compliance with certain provisions of the Financial Intelligence Centre Act, 2001. The publication does not set out new statutory requirements, effective dates, or consultation deadlines.

Key dates

2019-04-01

Start of the period covered by the SEC’s findings on untimely SAR investigations and filings

2024-03-31

End of the period covered by the SEC’s findings on untimely SAR investigations and filings

2024-08-12

SEC press release and administrative order were posted

2024-09-11 Deadline

Civil penalty payment due within 30 days of the order’s entry, assuming the posted order date reflects the entry date

Suggested considerations

• Compliance teams may wish to review SAR investigation aging standards against current internal procedures, especially for matters involving subpoenas, law-enforcement requests, or regulatory inquiries.
• Firms should consider whether escalation triggers, ownership, and sign-off responsibilities for SAR determinations are clearly documented across surveillance, legal, and compliance functions.
• Broker-dealers may wish to test whether case-management tools can identify stalled investigations and flag items approaching internal filing deadlines or reasonable-period expectations.
• Dual registrants may wish to assess whether broker-dealer and advisory compliance workflows are coordinated for suspicious-activity matters that cut across business lines.
• Training for relevant personnel may wish to be reviewed to ensure that SAR timeliness expectations and escalation protocols are understood by front office, surveillance, legal, and operations staff.

What changed

The publication does not create new rules or thresholds. It documents an enforcement action under Exchange Act Section 17(a) and Rule 17a-8, which require broker-dealers to file SARs for suspicious transactions and related activity. The SEC’s order emphasizes that firms must conduct and complete SAR investigations within a reasonable period of time, especially when the activity is connected to law-enforcement or regulatory inquiries. The outcome also shows that the SEC may treat delayed investigation and filing as a standalone compliance failure even without a substantive fraud finding.

Key dates

10 August 2026

- The WBF amended Annexes 2 and 8 of the Ukraine sanctions ordinance and published the changes on its website

12 August 2026 Deadline

- The amended measures are published by FINMA and become operationally relevant for compliance teams

12 August 2026, 23:00

- The amended sanctions measures enter into force

Suggested considerations

• Firms must immediately screen customers, counterparties, and beneficial owners against the updated Annex 2 and Annex 8 listings and identify any matches.
• Firms must block and freeze any assets or economic resources belonging to sanctioned persons covered by the updated ordinance.
• Firms must report the affected business relationships to SECO in accordance with the ordinance.
• Firms must perform additional fact-finding under Article 6 GwG/AMLA whenever the sanctions hit or surrounding facts create suspicion that cannot be dismissed.
• Firms must submit an immediate suspicious activity report to MROS under Article 9 GwG/AMLA if the suspicion remains unresolved after additional clarifications.

What changed

• - The WBF amended Annex 2 and Annex 8 of the Swiss ordinance on measures connected with the situation in Ukraine, updating the sanctions list and/or restrictions applicable under SR 946.231.176.72.
• The amended measures become effective today at 23:00, meaning firms must be ready to apply the updated prohibitions without delay.
• Financial intermediaries must implement the prohibitions contained in the ordinance, which includes sanctions-related restrictions beyond ordinary asset freezes.
• Financial intermediaries must freeze the assets of sanctioned persons covered by the update.
• Financial intermediaries must report affected business relationships to SECO.